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HIPAA Security Rule Resolves To Hit the Gym and Bulk Up

For more than 20 years, the HIPAA Security Rule has been virtually unchanged other than extending its scope beyond covered entities to also include business associates. During that time, technology has changed, cybersecurity...more

Whether Naughty or Nice, Compliance Deadline for HIPAA Reproductive Care Privacy Is Coming to Town

We just want to provide a friendly reminder that, before key staff depart for the holidays, HIPAA covered entities and business associates should finalize their compliance with the 2024 HIPAA amendments related to...more

OCR Updates Guidance on HIPAA and Online Tracking, But New Examples Lead to New Questions

Changes to guidance are unlikely to mitigate widespread concerns - On March 18, 2024, the U.S. Department of Health and Human Services Office for Civil Rights (OCR) revised its controversial guidance on how HIPAA applies...more

LEAP, Don't Run, to Make this YEAR's Deadline: HIPAA Small Breach Notifications Due February 29

February 29, 2024, is the date by which HIPAA-covered entities must notify the U.S. Department of Health and Human Services Office for Civil Rights (OCR) of all "small" breaches of unsecured protected health information that...more

Information Blocking Enforcement Is Here – Are You Ready?

The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) announced its final rule (the Enforcement Rule) implementing the information blocking penalties created by the 21st Century Cures Act...more

New Washington Law Has Broad Implications For Protecting Consumer Health Data - Landmark ‘My Health My Data’ Act Reaches Beyond...

On April 27, 2023, Washington Governor Jay Inslee signed into law the My Health My Data Act (the "Act"), which will regulate the collection, use, and disclosure of "consumer health data" ("Consumer Health Data" or "CHD"). The...more

OCR Proposes Amendments to HIPAA to Safeguard Reproductive Health Care Information in the Wake of Dobbs

Walking a middle path, the HHS Office for Civil Rights (OCR) published proposed amendments to the HIPAA Privacy Rule on April 17, 2023, to further safeguard the privacy of reproductive health care information. This comes in...more

Lessons Learned from OCR Reports to Congress on HIPAA Compliance and Data Breaches

To assist HIPAA-regulated entities to improve their compliance with HIPAA and their safeguarding of health information, the Department of Health and Human Services' Office for Civil Rights (OCR) delivered to Congress two...more

The Clock Is Ticking: HIPAA Small Breach Notifications Due March 1

HIPAA-covered entities must notify the U.S. Department of Health and Human Services Office for Civil Rights (OCR) of "small" breaches of unsecured protected health information that were discovered during calendar-year 2022 no...more

HHS Publishes Guidance on Using Online Tracking Technologies Under HIPAA

The U.S. Department of Health and Human Services Office for Civil Rights (OCR) issued a bulletin on December 1, 2022, clarifying that "regulated entities are not permitted to use tracking technologies in a manner that would...more

OCR Issues New Guidance Applying Security Rule to Digital Voice Transmissions and Storage

On June 13, 2022, the U.S. Department of Health and Human Services Office for Civil Rights (OCR) announced new guidance on using remote communication technologies to provide audio-only telehealth services in compliance with...more

Politics and PHI, Bad Online Reviews, and the Right of Access

The U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) announced four enforcement resolutions at the end of March 2022, with issues ranging from the misuse of protected health information (PHI)...more

The Clock Is Ticking: HIPAA Small Breach Notifications Due March 1st

March 1, 2022, is the date by which HIPAA-covered entities must notify the U.S. Department of Health and Human Services Office for Civil Rights (OCR) of "small" breaches of unsecured protected health information that were...more

Calendar Year 2020 HIPAA Small Breach Notifications Due March 1, 2021

March 1, 2021, is the due date for HIPAA-covered entities to notify the U.S. Department of Health and Human Services Office for Civil Rights (OCR) about "small" breaches of unsecured protected health information discovered...more

Help Is on the Way for Telehealth: Loosened HIPAA Enforcement

Telehealth is an essential tool in addressing the COVID-19 pandemic as well as in treating other ailments during this time. The Department of Health and Human Services' Office for Civil Rights (OCR) recently issued a...more

To Accept CMPs or Not to Accept CMPs?

In a Rare Imposition of HIPAA Civil Monetary Penalties (CMPs) Rather than Settlement, What to Accept May Have Been the Question - On October 23, 2019, the Department of Health and Human Services Office for Civil Rights...more

HHS Reinterprets (and Significantly Lowers) Annual Penalty Caps for HIPAA Violations

The Department of Health and Human Services Office for Civil Rights (OCR) today announced that it is lowering the maximum total penalties it may assess against covered entities and business associates for multiple violations...more

HIPAA Small Breach Notifications Due March 1

March 1, 2019 is the date by which HIPAA covered entities must notify the U.S. Department of Health and Human Services Office for Civil Rights (OCR) of “small” breaches of unsecured protected health information that were...more

Where Is the HIPAA Right to Defend One’s Self?

When a patient publicly disparages a health care provider, HIPAA leaves the health care provider in a seemingly impossible situation. If the health care provider does not respond and dispute the allegation, then its...more

Lights, Camera, Action!: HIPAA Enforcement for Camera Crews on Hospital Premises

HIPAA and 15-minutes-of-fame are not compatible. In September 2018, the federal Department of Health and Human Services, Office for Civil Rights (“OCR”) announced that it had reached settlements with Boston Medical Center...more

Is OCR Moving the Goal Posts on Vendor Management?

Recent statements at the 27th National HIPAA Summit suggest that the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) may be changing its position and expecting a greater level of vendor due...more

Privacy Please: HIPAA and Artificial Intelligence – Part I

What if Artificial Intelligence (AI) is deployed within a health system to apply machine learning to patient information, in part, to allow patients to download information and wellness numbers (such as steps, blood pressure,...more

HIPAA Small Breach Notifications Due March 1

March 1, 2018 is the date by which HIPAA covered entities must notify the U.S. Department of Health and Human Services Office for Civil Rights (OCR) of “small” breaches of unsecured protected health information that were...more

ACA’s Nondiscrimination Taglines and Notices Require Updating Your Notice of Privacy Practices

There has been confusion as to whether the Affordable Care Act’s nondiscrimination provision (“ACA”) affects a covered entity’s notice of privacy practices (“NPP”) or data breach notifications. OCR has issued guidance...more

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